Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
None.
Item 1C. Cybersecurity.
Risk Management and Strategy
We
have established policies and processes for assessing, identifying, and managing material risk from cybersecurity threats and integrated
these processes into our overall risk management systems and processes. We assess material risks from cybersecurity threats, including
any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality,
integrity, or availability of our information systems or any information residing therein.
We
conduct technical risk assessments to identify cybersecurity threats, as well as assessments in the event of a material change in
our business practices that may affect information systems that are vulnerable to such cybersecurity threats. We also plan to
conduct programmatic risk assessments including identification of reasonably foreseeable internal and external risks, the likelihood
and potential damage that could result from such risks, and the sufficiency of existing policies, procedures, systems, and
safeguards in place to manage such risks.
Following
these risk assessments, we will evaluate whether and how to re-design, implement, and maintain reasonable safeguards to minimize
identified risks; evaluate how to reasonably address any identified gaps in existing safeguards; and regularly monitor the
effectiveness of our safeguards. Our Manager of Information Technology, who has over 20 years of information technology experience,
and our Chief Operating Officer, who has over 10 years of information technology management experience, manage the risk assessment and mitigation process.
As
part of our overall risk management system, we monitor and test our safeguards and train our employees on these safeguards, in collaboration
with human resources, information technology and management. Personnel at all levels and departments are made aware of our cybersecurity
policies through internal communications, training and annual policy updates, and are requested to promptly report any suspected breach
of our information systems to management.
For
additional information regarding whether any risks from cybersecurity threats, including as a result of any previous cybersecurity
incidents, have materially affected or are reasonably likely to materially affect us, including our business strategy, results of
operations, or financial condition, please refer to Item 1A, “Risk Factors,” in this Report on Form 10-K, including the
risk factors entitled “Third parties might attempt to gain unauthorized access to our network or seek to compromise our
products and services.”
Governance
A role of our board of directors
is informed oversight of our risk management process, including risks from cybersecurity threats. Our board of directors is responsible
for monitoring and assessing strategic risk exposure, and our management is responsible for the day-to-day management of the material
risks we face. Our board of directors administers its cybersecurity risk function in coordination with the oversight and periodic review
of the audit committee. In the event of a cybersecurity incident impacting us, management will report to our board of directors and provide
updates on management’s incident response plan for addressing and mitigating any risks associated with such an incident.
Our cybersecurity incident response and vulnerability management policies are designed to escalate certain cybersecurity incidents and
threats to management members depending on the circumstances, including the Chief Executive Officer and Chief Financial Officer. The Chief
Executive Officer and Chief Financial Officer work with our incident response team in an effort to help the Company mitigate and remediate
cybersecurity incidents of which they are notified. In addition, the Company’s management and its designees report to the board
of directors for certain cybersecurity incidents.
Our board of directors will receive periodic reports from management and its designees
concerning our significant cybersecurity threats and risks, and the processes we plan to implement and/or have implemented in an effort
to address them.
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